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CHRYSLER CORP. v. C.I.R.

No. 03-1214.

436 F.3d 644 (2005)

CHRYSLER CORPORATION, fka Chrysler Holding Corporation, as Successor by Merger to Chrysler Motors Corporation and its Consolidated Subsidiaries, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: February 8, 2006.

Attorney(s) appearing for the Case

ARGUED: Jennifer L. Fuller, Kenneth B. Clark, Fenwick & West, Mountain View, California, for Appellant. Joan I. Oppenheimer, Bridget M. Rowan, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Jennifer L. Fuller, Kenneth B. Clark, William F. Colgin, Barton W.S. Bassett, James P. Fuller, Ronald B. Schrotenboer, Fenwick & West, Mountain View, California, for Appellant. Joan I. Oppenheimer, Gilbert S. Rothenberg, Charles Bricken, United States Department of Justice, Washington, D.C., for Appellee.

Before: BOGGS, Chief Judge; NORRIS and COOK, Circuit Judges.

OPINION

ALAN E. NORRIS, Circuit Judge.

Chrysler Corporation appeals from three adverse Tax Court rulings that granted partial summary judgment to the Commissioner of Internal Revenue. The disputed tax computations stem from the early to mid-1980s and involve substantial sums of potential tax liability. These rulings present the following questions: 1) Under the accrual accounting method used by Chrysler, was the company permitted to deduct anticipated warranty...

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